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a comparable level are allowed to provide each of the core services independently in all states. As with psychologists, there is a lower level of licensure, offered in 32 of the states we surveyed. Only North Dakota and West Virginia allow independent practice at this level.

Tables 5 and 6 offer convincing evidence that scope of practice laws should not be used as a basis for payment policies. Since diagnosis and psychotherapy are the only Medicare reimbursable mental health services of those studied here, one might expect to find the two professions currently eligible for Medicare reimbursement (psychologists and social workers) to be licensed in these areas in all states. While no state explicitly restricts any of the licensed professions from performing these services, many simply do not address them. Three states fail to mention diagnosis, and five fail to mention psychotherapy in the scope of practice for psychologists. For both social workers and MFTs, 10 states fail to mention diagnosis and nine fail to mention psychotherapy, and for LPCs, 14 states fail to mention diagnosis and 21 fail to mention psychotherapy. (See Table 7 for a summary.)

Training and Supervision Prior To Licensure

Although there is some minor variation, the 40 states we studied have generally comparable requirements for the education and supervised practice needed to be licensed for each profession. In all but four states, a Psychologist must have a PhD to practice independently, while the other professions allow independent practice at the Masters level. Typical training and hours of supervised practice for the most independent level of practice for each discipline are as follows:

  • Psychologist (PhD): Doctorate in psychology and two years of supervised clinical experience. Typically, one year is completed while earning the doctorate and the second is completed after graduation.

  • Psychologist (Masters): (This training is typical only in the four states that allow the Masters level Psychologist to practice independently: Alaska, Kansas, Vermont and West Virginia). Masters in Psychology and two years of supervised clinical experience. (In WV, five years of experience.)

  • Licensed Clinical Social Worker: Master’s or doctorate in social work and two years of

supervised clinical experience. When the requirements for actual face-to-face supervision


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